1d or 3d: Choosing a Declaration Scheme for EMC and LVD

Why did the scheme question start being asked?

Two changes made certification schemes a live topic rather than a technicality.

The certification system in the Customs Union countries became considerably more rigorous. Requests along the lines of “I need the certificate tomorrow, no sample, no audit” stopped being viable; the procedure now follows the intent of each technical regulation, and the manufacturer goes through it properly.

Clients also started wanting to understand which scheme fits, so they could weigh the risks in advance and not discover them later.

The two schemes

Taking TR CU 020/2011 (EMC) or TR CU 004/2011 (LVD) as the example, serially produced products have two main schemes for issuing a declaration of conformity.

There is a third form, the certificate of conformity, and it raises no scheme question: testing must be done in an accredited laboratory inside the Union.

What does scheme 1d permit?

If your electronic device needs a declaration under EMC or LVD, scheme 1d means you investigate the standards that apply to your product, they are listed in the annexes to the technical regulation, usually with a GOST prefix, and satisfy yourself that the product conforms.

That can be done through testing in the manufacturer’s own laboratory, or by applying to any other laboratory. It is the applicant’s decision how conformity is demonstrated.

Under 3d you go instead to an accredited Customs Union laboratory whose competence has been confirmed by the national accreditation body, which guarantees the quality of the sampling and the tests.

Can foreign test reports be used under scheme 1d?

Common practice for years has held that foreign test reports to IEC standards cannot serve as evidence, even under scheme 1d, simply because certification providers became used to accepting only reports produced in Customs Union laboratories.

There is not a word in TR CU 020 or TR CU 004 requiring reports of Customs Union origin under scheme 1d.

The reason IEC reports can work is in the annexes. The list of GOST standards attached to TR CU 020 references IEC analogues. For example, GOST 30886-2002 states in its own text that it is identical to EN 55103-1:1996, so a test report against EN 55103-1:1996 demonstrates that the product meets the requirements the TR CU imposes.

The three routes, stated plainly

1. Scheme 1d with reports issued in a laboratory located in the Customs Union.
2. Scheme 1d with reports issued in the manufacturer’s own laboratory, or a European testing laboratory.
3. Scheme 3d with reports issued in an accredited certification laboratory in the Customs Union.

Route 2 is the one most often left on the table. Before commissioning new testing, check whether the GOST that applies to your product declares itself identical to a standard you have already tested against.

Sources

• TR CU 020/2011, Electromagnetic compatibility of technical means, Eurasian Economic Commission, and its annex list of standards
• TR CU 004/2011, On the safety of low-voltage equipment
• GOST 30886-2002 and EN 55103-1:1996, the identity relationship cited above
• Customs Union Common Register of Certification Bodies and Testing Laboratories